WINDNFIRE: AML/KYC POLICY

Publication date "11" April 2022

The AML/KYC Policy (hereinafter referred to as the "Policy") is designed to prevent and reduce possible risks of the Company's involvement in any illegal activity.

The Policy indicates the jurisdictions in which the Company does not provide its Services due to the prohibition at the international level on combating money laundering and the financing of terrorism.

The Policy indicates the jurisdictions, residents of which WINDNFIRE may provide the Services. WINDNFIRE does not operate or advertise its Services in these countries. WINDNFIRE provides Services to residents of such jurisdiction, if the resident independently enters the Site and uses the Services.

References to the words "we", "our" or "us" (or similar words within the meaning) mean the WINDNFIRE Company.

References to the words "you", "you" or "your" (or similar words within the meaning) mean our Client, depending on the context of the AML/KYC Policy.

Also, WINDNFIRE regulates its activities in the framework of legislation on combating money laundering and terrorist financing.

1. DEFINITIONS

1.1. Client - an individual or legal entity that interacts with the Company to receive the Services.

1.2. Client’s Consent (hereinafter "Consent") - means a voluntary, specific, informed, and unequivocal expression of will, in which the Client using a statement or explicit affirmative action agrees to the Processing of his Personal Data.

1.3. Personal Data - means any information that directly or indirectly allows identifying the Client. For example, name, surname, phone number, IP address.

1.4. Services means the promotion of a company and/or a product and/or a page in social networks, complex of actions for using social services as channels for the promotion of a company and/or a product and/or a page and solution of other business tasks, with or without the involvement of third parties.

1.5. WINDNFIRE (hereinafter referred to as "the Company" or "WINDNFIRE") - is a company on the Internet that provides digital marketing services to the Client.

2. MONEY LAUNDERING AND TERRORIST FINANCING PREVENTION LEGISLATION

2.1. WINDNFIRE is committed to complying with the laws governing money laundering and terrorist financing.

2.2. WINDNFIRE is governed by the following anti-money laundering and terrorist financing laws:
2.2.1Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs);

2.2.25th Anti-Money Laundering Directive ((EU) 2018/843).

2.3. In addition, Company may partner with the following organizations in the fight against money laundering and terrorist financing:
2.3.1Financial Action Task Force (FATF);

2.3.2Joint Money Laundering Steering Group (JMLSG);

2.3.3FCA Handbook

3. INSPECTION PROCEDURE

3.1. WINDNFIRE has the right to ask you to provide your name, address, date of birth and other information about you in order to verify your residency.

3.2. The Company may ask you to provide certain identification documents, such as your driver's license or passport, to verify your identity.

3.3. If you do not provide the requested information and documentation, we have the right to refuse to provide you with the Services.

3.4. For due diligence of Clients, WINDNFIRE requires Clients to provide WINDNFIRE with valid original documents for their identification. Such documents may include, for example, national identity card, international passport.

3.5. WINDNFIRE will take steps to verify the authenticity of documents and information provided by the Client. The Company may also verify Personal Data using secondary sources.

3.6. WINDNFIRE reserves the right to control the Client's Personal Data on an ongoing basis, especially when his identification information has been changed or his actions seemed suspicious (unusual for a particular Client). In addition, the Company reserves the right to request up-to-date documents from the Client, even if they have been authenticated in the past.

3.7. If the Client pays for the Company's services in cryptocurrency, the Company has the right to:


3.7.1 check the origin of cryptocurrency;

3.7.2 to check transactions with the help of special services;

3.7.3 check the "purity" of cryptocurrency;

3.7.4 request from the Client any documents to prove the origin of the cryptocurrency.

3.8. In order to fulfill its obligations to combat money laundering and counter the financing of terrorism, WINDNFIRE conducts an annual risk assessment. The purpose of the risk assessment is to prevent criminals from using WINDNFIRE for money laundering by highlighting the risks and assessing the controls set up by WINDNFIRE to identify the Client and track how they use the Company.

3.9. After checking the Client, the Company may refuse the Client, without providing any explanation or any consequences for its side, to provide the Services in a situation where there is a suspicion that the Company will be used for illegal activities, including but not limited to "Money Laundering" and/or the Client is in a jurisdiction with which any relationship is prohibited.

4. HIGH-RISK JURISDICTIONS

4.1. WINDNFIRE defines the risk criteria for providing the Services to residents located in countries subject to sanctions and considered high-risk areas.

4.2. Sources used to identify high-risk jurisdictions:
4.2.1Transparency International;

4.2.2Know Your Customer (Anti-money laundering (AMLD IV) - Directive (EU) 2015/849);

4.2.3FATF High Risk Jurisdictions;

4.2.4EU High Risk Jurisdictions;

4.2.5Countries subject to UNSC Sanctions Regime.

4.3. Full list of prohibited jurisdictions:

Afghanistan Ecuador Nepal
Albania Egypt Nicaragua
Angola Equatorial Guinea North Macedonia
Algeria Eritrea Pakistan
Bangladesh Ghana Panama
Barbados Guinea-Bissau Qatar
Bolivia Guyana Saudi Arabia
Botswana Haiti Somalia
Burma (Myanmar) Iran South Sudan
Burundi Iraq Sudan
Cambodia Jamaica Syria
Central African Republic Lao People's Democratic Republic Tunisia
Chad Lebanon Uganda
Congo Libya Vanuatu
Guinea - Conakry Mali Venezuela
Ivory Coast Morocco Yemen
Crimea, Ukraine Myanmar Zimbabwe
Cuba
Democratic People's Republic of Korea (DPRK)

4.4. In accordance with the Policy, the Company has the right to refuse all Clients residing in the countries listed in clause 4.3. Poliсу.

4.5. The Company also does not accept clients from disputed territories, as they do not provide recognized official documents, including:


4.5.1 Donetsk People's Republic (DPR) / Luhansk People's Republic (LPR);

4.5.2 Pridnestrovian Moldavian Republic;

4.5.3 Nagorno-Karabakh Republic;

4.5.4 Republic of Abkhazia;

4.5.5 Republic of Somaliland;

4.5.6 Republic of South Ossetia;

4.5.7 Republic of Kosovo;

4.5.8 Republic of China (Taiwan);

4.5.9 Sahara Arab Democratic Republic;

4.5.10 Artsakh Republic

5. CLIENT CONSENT

5.1. The Client confirms that he agrees with the terms of this Policy and agrees to take all actions and provide all documents or information that the Company may require to verify the origin of its funds, including verification of the origin of cryptocurrency, in accordance with the terms of this Policy.

6. CONTACTS

6.1. If you would like to ask questions, leave feedback, or are concerned about interacting with the Company, please contact support at: [email protected]